UK Bookmaker Affordability Checks

The big issues of the forthcoming gambling review white paper and the affordability checks which have been introduced in recent years by online sportsbooks have been at the forefront of many racing and betting fans’ minds in the past few months.

The turmoil in the Conservative government, various changes in leadership and other issues in Westminster has seen the gambling white paper shelved a number of times with the paper set to be published as a result of a gambling review announced back in 2019.

A large number of high profile racing personalities, most notably trainers John Gosden and Nicky Henderson and Highclere Thoroughbred Racing chief Harry Herbert have spoken out about the issue and how the enforcement of affordability checks may force punters to the black market.

Cabinet Reshuffle

It’s worth noting at an early stage when considering the various knock on effects of affordability checks that the current state of UK politics, the various changes in Prime Minister (three in the last year for example) and creation of new positions has led to some blurring of the lines with regards to what exactly is and isn’t required from an affordability check viewpoint.

One of those positions is the Parliamentary Under-Secretary for Tech and the Digital Economy, a junior role in the government but ultimately responsible for gambling.

With the removal of Paul Scully from the position, one he’d held since October 2022 the government will be onto its fourth appointment to the job since 2021 with Chris Philp and Damian Collins also having held the position.  

Funding Checks 

Checks on pay slips and bank accounts are increasing and according to some becoming the norm for punters wishing to get an ordinary bet on with many pudits on social media claiming such checks are an added layer of protection against “unprofitable business”, or winning accounts.

While understandably an emotive topic, particularly for those who have relatives who have been harmed by gambling it’s important that any further restrictions and checks on punters don’t infringe too much on freedom of choice, that is the freedom for the individual to spend their money as they see fit ala with other “vices” such as cigarettes and alcohol.

While the current round of affordability checks seemingly only effects a relatively small number of punters, the industry and those who depend on it for a living and to fund their businesses and/or lifestyle should be particularly worried that a study in 2022 found that 70% of people who bet would be unwilling to allow regulated firms to carry out such checks so they could place a bet.

While it’s unknown whether such punters would head to the black market or stop betting altogether it is undoubtedly a negative for sports like horse racing which is almost entirely reliant on income from betting for its prize money. 

I’ve been unable to find figures for the amount currently bet on the black market in the UK but studies suggest that the figure tops 50% in both Norway and France. 

While the latter has seen a more open market than has been the case in previous years the current state of affairs and historic openness and choice available to the UK sports punter with upwards of 50 bookmakers plus betting exchanges and in some cases the Tote available as outlets for punting must raise concerns that a UK black market could potentially handle the vast majority of bets placed by UK punters at some point down the line.

Having seen examples cited on social media in recent weeks of people being asked to provide friends’ bank account and payslip details it’s become quite clear that some firms are going above and beyond the call of duty in this regard.

Affordability Check Levels

While due diligence has always been done on customers and evidence for source of funds is generally required once a punter hits a certain level with a bookmaker it’s notable just how far the level for affordability checks has fallen in recent years.

888 Holdings, now the parent company for William Hill were reported in a Racing Post article by Bill Barber just under two months ago, that they would be reducing their affordability check trigger from £950 to £500 with that number having been as high as £2000 back in 2021.

A quick look at the active accounts I have, which admittedly aren’t as extensive as they once were suggests that among the various safety controls that a punter can put on their account are deposit limits, cooling off periods and a reality check with the latter being a time limit on your gambling activity.

Those are in addition to the traditional “self exclusion” tools which since I started working in the industry back in 2005 has always been an option for punters.

Perhaps the most worrying thing of all is how widespread such affordability checks seem to be. Account restrictions, while a pain for successful punters are nowhere near as widespread as people like to make out with many recreational punters never encountering a restriction.

However that seems unlikely to be the case with the affordability checks, particularly if the limits are set at £500 or lower which could see many recreational sports and racing punters hit the limit within four or five months of opening an account depending on how they punt.

Gambling Commission Fines 

While some who are vocal on social media and elsewhere view these affordability checks as a way of imposing account restrictions via the back door it’s hard not to have sympathy with the firms who are imposing them.

The Gambling Commission, the body responsible for regulating gambling in the UK and who, depending on who you ask, are doing an outstanding job, or a terrible one, regularly impose fines on sportsbooks who breach responsible gambling regulations and/or fail vulnerable customers.

However there doesn’t seem to be any set list of procedures required or indeed a limit set by the Commission to ensure that firms don’t fall foul of such regulations.

The fines aren’t small with eight fines in excess of a million pounds handed out since the start of 2022, including one of £17M handed out to Entain (holding company of Ladbrokes and Coral among others) for “social responsibility and anti-money laundering failures”.

Andrew Rhodes At ICE 2023

It seems particularly poignant to look at the subject this week with the gambling industries big ICE conference currently taking place in London. 

Gambling Commission chief executive Andrew Rhodes’ speech on Wednesday was of particular interest with regards responsible gambling with Rhodes pointing out that the number of punters losing more than £500 a month with the larger betting operators had dropped by 8%.

Rhodes was keen to point out that the Gambling Commission’s casework found that there were still too many unacceptable levels of gambling being entertained by gambling operators.

Stories of health care staff losing nearly £250,000 in a three month period and a new customer able to lose £70,000 in a ten hour gambling spell the day after opening an account are two such cases that Rhodes used as examples.

I doubt many readers will find such levels of losses acceptable but it’s important to find a happy medium with regards to checks and losses. 

While the “Setting the Evidence Agenda” which has been set up by the Gambling Commission to bring academics and operators among others to the table to discuss how the industry as a whole can improve has all the hallmarks of a BHA steering group and the potential to be as big a waste of time and money as last years Everyone’s Turf campaign it sounds like a positive step.

I’d like to see the Setting the Evidence Agenda garner evidence from both academics who are keen to ensure a safer gambling market and operators who no doubt want to maximise profits, ensure punter safety and avoid fines.

Such evidence would then I hope be put towards developing policies and procedures that can be implemented across the industry. 

Going Forward

Should there be set affordability check levels? 

It would make sense for the Gambling Commission to publish a more detailed guide with regards to responsible gambling and affordability checks. 

A list of actions for firms to take with regards to accounts who are winning and/or losing and at what stage such actions need to be implemented.

The current situation seems to be a bit of a free for all with some punters being asked for details as soon as they try to withdraw and others only once they hit a certain, unpublished limit.

While I can’t profess to be an expert on what exactly should be required I’d definitely look towards an industry standard approach to both affordability checks and responsible gambling, a set level at which punters are asked to provide proof of funds and affordability.

Until then the future of the UK gambling industry looks at best uncertain, and I’d be in no doubt that the government, operators, safer gambling and anti-gambling bodies wouldn’t want punters heading towards a black market and nor would sports such as horse racing which are heavily reliant on the collection of the levy to fund race meetings.